Blum v. Commissioner
United States Tax Court
The acquisition by a corporation of all of one class of stock which was to be redeemed according to the terms of the stock is within section 115 (i) and (c), Internal Revenue Code, treating the gain to the shareholder as a short term capital gain, regardless of an original contract assumed by the corporation to purchase the stock, where, after assignment of the contract to the corporation, the stockholders adopted a plan of recapitalization under which three classes of stock…
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The acquisition by a corporation of all of one class of stock which was to be redeemed according to the terms of the stock is within section 115 (i) and (c), Internal Revenue Code, treating the gain to the shareholder as a short term capital gain, regardless of an original contract assumed by the corporation to purchase the stock, where, after assignment of the contract to the corporation, the stockholders adopted a plan of recapitalization under which three classes of stock were issued, one class being issued in exchange for the stock covered by the contract, with the clearly stated…
1Opinion of the Court
Gladys C. Blum, Petitioner, v. Commissioner of Internal Revenue, Respondent
Blum v. Commissioner
Docket No. 5791
United States Tax Court
5 T.C. 303; 1945 U.S. Tax Ct. LEXIS 139;
June 21, 1945, Promulgated
Decision will be entered for the respondent.
The acquisition by a corporation of all of one class of stock which was to be redeemed according to the terms of the stock is within section 115 (i) and (c), Internal Revenue Code, treating the gain to the shareholder as a short term capital gain, regardless of an original contract assumed by the corporation to purchase the stock, where, after assignment…
2Cases cited3 opinions
- Allport v. CommissionerUnited States Tax Court · 1944
- Jones v. CommissionerUnited States Tax Court · 1945
- Blum v. CommissionerUnited States Tax Court · 1945